Privacy Practices

This notice describes how medical information about you may be used and disclosed and how you can get access to this information.

Please review it carefully.

At St. Anthony’s Medical Center, we recognize that health care services are among the most personal services you and your loved ones can receive. Rest assured that we respect, and are bound by law, to protect the privacy of your personal health information. There are specific occasions however, when we must share this information. This Notice of Privacy Practices, first implemented on April 14, 2003, with the most recent revisions effective September 23, 2013, outlines the conditions under which your personal health information may be used or disclosed and how you can access this information. Please review it carefully and in full.

Our Responsibilities and Pledge Regarding Your Medical Information

Each time you visit a hospital, physician, or other health care provider, a record of your visit is made. Typically, this record contains your symptoms, examination and test results, diagnoses, treatment, a plan for future care or treatment, and billing information. We understand that this information, often referred to as your health or medical record, is personal.

We are committed to protecting your medical information, and are required by law to do so. This Notice of Privacy Practices (the “Notice”) applies to all of the records of your care and generated by St. Anthony’s Medical Center and its affiliated facilities, whether made by St. Anthony’s Medical Center personnel, your personal doctor, or companies that we contract with to perform certain duties on our behalf. Your personal doctor may have different policies or notices regarding the doctor’s use and disclosure of your medical information created in the doctor’s office or clinic.

We are required by law to maintain the privacy of your medical information, provide you with this Notice, and comply with the Notice that is currently in effect. This Notice will tell you about the ways in which we may use and disclose your medical information. We also describe your rights and certain obligations we have regarding the use and disclosure of medical information. With a few exceptions, we are required to obtain your authorization for the use and disclosure of information for reasons other than treatment, payment or health care operations. This Notice will list some of the reasons why we might use or disclose your medical information and provide examples of these uses and disclosures. We will notify you of any incidents with your information that compromise its security or privacy (these incidents are called breaches of your unsecured protected health information). We will provide you with a copy of the current Notice the first time you register at or are admitted to St. Anthony’s Medical Center or its affiliates for treatment or health care services as an inpatient or outpatient on or after April 14, 2003. We will also post a copy of the current Notice in the hospital building and in the buildings of our affiliated facilities.

We may change our privacy practices and revise our Notice effective for all medical information we maintain. The Notice will contain the effective date at the top of the page. If we have already provided you with a copy of the Notice, and later our privacy practices change and we revise our Notice, you may obtain a copy of the revised Notice by (1) asking for a copy of the current Notice to take home with you the next time you visit or receive health care services at St. Anthony’s Medical Center or one of its affiliates, (2) printing this Notice, or (3) submitting your request in writing to the Privacy Officer at St. Anthony’s Medical Center, 10010 Kennerly Road, St. Louis, MO 63128.

Who Will Follow This Notice

This Notice describes St. Anthony’s Medical Center’s practices and those of other individuals and entities participating in an organized health care arrangement with St. Anthony’s Medical Center, including:

All departments and units of the hospital.

Any member of a volunteer group we allow to help you while you are in the hospital.

Members of the Medical, Dental and Podiatric Staff and Allied Health Professional Staff (the “Staff”) of St. Anthony’s Medical Center and other independent health care providers, when creating or using information in medical records maintained by St. Anthony’s Medical Center.

Any of the individuals or entities described in this section will share your medical information with each other as necessary for purposes of treatment, payment, and health care operations related to this organized health care arrangement. Members of the Staff, including your personal physician and other independent health care providers, may have different privacy policies and practices relating to their use or disclosure of medical information created or maintained outside St. Anthony’s Medical Center, such as in their clinics or offices. The fact that members of the Staff and other independent providers are subject to this Notice does not mean that they are operating as agents or joint ventures of St. Anthony’s Medical Center, and will not affect the medical decisions they make in your care and treatment.

How We May Use and Disclose Your Medical Information

The following categories describe different ways that we use and disclose medical information. For each category of uses or disclosures we will explain
what we mean and try to give some examples. Not every use or disclosure in a category will be listed.

Some uses and disclosures of medical information may be subject to additional restrictions under federal and state laws and regulations, such as those that apply to substance abuse treatment, HIV/AIDS testing and treatment, and mental health treatment. For example if you are receiving alcohol or drug abuse services, information that would identify you as a person seeking help for a substance abuse problem is protected under a separate set of federal regulations known as “Confidentiality of Alcohol and Drug Abuse Patient Records”, 42 C.F.R. Part 2. Under certain circumstances these regulations will provide your medical information with additional privacy protections beyond what is described in this Notice.

Treatment. To provide you with medical treatment or services, we may need to use or disclose your information to doctors, nurses, technicians, students, and pharmacists. We may also disclose your medical information to people who may be involved in your medical care after you are discharged, such as your primary care physician, home health agencies and social service staff. We may also disclose information to other health care providers that are not our employees or affiliates but that are involved in your treatment (e.g., long term care facilities, emergency medical providers and unaffiliated physicians).

Payment. We may use and disclose your medical information to bill and receive payment for the treatment you receive here. For example, we may disclose your medical information to your insurance company about a service you received so that your insurance company will pay us or reimburse you for the service. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.

Health Care Operations. We may use and disclose your medical information as necessary to run the hospital and its affiliates and to make sure that you receive quality care. For example, we may use and disclose medical information to conduct our business management and general administrative activities. We may also review medical information to evaluate our treatment and services and the performance of our employees in caring for you. In some cases we may use and disclose medical information about a group of patients (for example, patients who are being treated for a certain condition or who receive care from a particular department) in an effort to continually improve the quality and effectiveness of the health care and services we provide. We may also disclose information to doctors, nurses, technicians, medical students, and other personnel for review and learning purposes. We may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery.

Other Providers. We may disclose your medical information to other providers involved in your care for their use in your treatment, in obtaining payment for your treatment and for their health care operations.

Business Associates. There are some services provided in our organization through contracts with certain individuals and companies, which are called business associates. Examples of business associates include a copy service we use when making copies of your health record, a software vendor who will assist us with our computer system and our billing service that assists us with billing insurance companies and third-party payers. When we contract with our business associates, we may disclose your medical information to our business associates so that they can perform the job we have asked them to do. To protect your medical information, however, we require our business associates to appropriately safeguard your information and uphold the same confidentiality standards that we are required to meet.

Appointment Reminders and/or Pre-Registration. We may use or disclose your health information to remind you of appointments or to pre-register you for a hospital stay or procedure. We may leave messages at your work or home locations, or send you letters or postcards as appointment reminders.

Fundraising Activities. We may use information about you to contact you and your family in an effort to raise money for our operations. We may disclose limited demographic information, such as your name, address, phone number, dates you received treatment or services from us, department where you received treatment or services, treating physician, and general information about the outcome of your treatment to a foundation related to the hospital so that the foundation may contact you. At any time, you may opt out of receiving more communications about fundraising for the hospital. The hospital will not condition treatment or payment on your choice whether or not to receive fundraising communications.

Treatment Alternatives. We may use and disclose your medical information to tell you about or recommend possible treatment options and alternatives that may be of interest to you. If the hospital receives payment for making the communication, it is generally considered marketing and your authorization will be required.

Health-Related Benefits and Services. We may use and disclose your medical information to tell you about health-related benefits or services that may be of interest to you. For example, we may send you a newsletter or other mailing about our services, products, educational programs and wellness programs. If you receive hospice services, we may send information to your family regarding support services we provide to those whose loved ones may be seriously ill. If the hospital receives payment for making the communication, it is generally considered marketing and your authorization will be required.

Hospital Directory. We will include certain limited information about you in the hospital directory while you are a patient at the hospital. This information may include your name, location in the hospital, your general condition (e.g., undetermined, good, fair, serious, and critical) and your religious affiliation, if furnished by you. Unless you tell us not to, the directory information, except for your religious affiliation, may be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy, such as a priest or rabbi, even if that person doesn't ask for you by name. The directory is used so your family, friends and clergy can visit you in the hospital and generally know how you are doing. Also, this information is used so that you can receive gifts, flowers and cards that are sent to you while you are in the hospital.

Individuals Involved in Your Care or Payment for Your Care. We may tell your family or friends your general condition and that you are in the hospital. Unless you object, we may disclose to a member of your family, a relative, a close friend or any other person you identify, your medical information that directly relates to that person’s involvement in your health care. If you are unable to agree or object to such a disclosure, we may disclose such information as necessary if we determine that it is in your best interest based on our judgment. In addition, we may disclose medical information about you to an entity assisting in a disaster relief effort (for example, the American Red Cross) so your family can be notified about your condition, status and location. After your death, we may continue to disclose information to individuals who were involved in your care, unless you have objected.

Research. Under certain circumstances, we may use and disclose your medical information for research purposes. On occasion, researchers contact patients regarding their interest in participating in certain research studies. These research studies are subject to a special approval process through our institutional Review Board, but we may disclose medical information about you to people preparing to conduct a research project, for example, to help them look for patients with specific medical needs, so long as the medical information they review is used only for this purpose. Enrollment in these studies can only occur after you have been informed about the study, had an opportunity to ask questions, and indicated your willingness to participate in the study by signing a consent form. Other studies may be performed using your medical information without requiring your consent. These studies will not affect your treatment or welfare, and your medical information will continue to be protected. For example, a research study may involve comparing the health and recovery of all patients who received one medication to those who received another for the same condition.

As Required By Law. We will disclose your medical information when we are required to do so by federal, state or local law.

To Avert a Serious Threat to Health or Safety. We may use and disclose your medical information when necessary to prevent a serious threat to your health and safety or the health and safety of any other person(s).

Public Health Activities. We may disclose your medical information to a public health or other government authority that is permitted by law to collect or receive the information. The disclosure may be necessary to do the following:
— Prevent or control disease, injury or disability.
— Report births and deaths.
— Report child abuse or neglect.
— Report reactions to medications or problems with health care products.
— Notify people of recalls of products they may be using.
— Notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition.
— Notify the appropriate government authority if we believe you have been the victim of abuse or neglect. We will only make this disclosure if you agree or when we are required to do so by law.
— Report adverse events with respect to food, supplements, and product defects, or post marketing surveillance information to enable product recalls, repairs, or replacement.
— Provide proof of your immunizations to a school at your request or the request of your parent or guardian.

Health Oversight Activities. We may disclose your medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and activities related to our licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

Lawsuits and Disputes. We may disclose your medical information in response to a court or administrative order. In certain circumstances, we may also disclose your medical information in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute.

Law Enforcement. We may release your medical information to a properly identified law enforcement official in the following situations:
— In response to a court order, subpoena, warrant, summons or similar process.
— To assist law enforcement to identify or locate a suspect, fugitive, material witness or missing person.
— In certain limited circumstances, if you are, or we suspect you are, the victim of a crime and we are unable to obtain your agreement.
— If we believe that a death may be the result of criminal conduct.
— If we believe that the information constitutes evidence of criminal conduct occurring on our premises.
— In emergency circumstances to report a crime, if it appears necessary to disclose the information related to the commission and nature of a crime, the location of the crime or victims, or the identity, description or location of the person who committed the crime.

Uses and Disclosures About Decedents. We may release information about a deceased person to a coroner or medical examiner to identify the person, determine the cause of death or perform other duties recognized by law. We may also release medical information to funeral directors as necessary to carry out their duties.

Military and Veterans. If you are a member of the armed forces, we may disclose your medical information as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.

National Security, Intelligence and Protective Activities. We may disclose your medical information to authorized officials for intelligence, counterintelligence, and other national security activities authorized by law, and so that they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.

Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may disclose your medical
information to the correctional institution or law enforcement official as necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.

Workers’ Compensation. We may disclose your medical information as authorized by, and to the extent necessary to comply with, laws relating to workers’ compensation or similar programs that provide benefits for work related injuries or illness.

Uses and Disclosure Requiring your Written Authorization. Other uses and disclosures of your medical information not covered by this Notice or the laws that apply to us will be made only with your specific written authorization. Uses and disclosures that require your authorization include use and disclosure of psychotherapy notes, use and disclosure for marketing (other than face to face communications and small, promotional gifts), and other disclosures that the hospital would get paid to make, with some exceptions. If you provide us authorization to use or disclose medical information about you, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose your medical information for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your authorization, and that we are required to retain our records of the care that we provided to you.

Your Rights

Although your health record is the physical property of St. Anthony’s Medical Center, the information contained in the record belongs to you. You have the following rights with respect to your medical information that we maintain:

The Right to Request Restrictions
You have the right to request a restriction or limitation on how we use and disclose your medical information for treatment, payment and health care operations. You also have a right to request a limitation on the medical information that we disclose to someone who is involved in your care or payment for such care, such as a family member or friend. To request restrictions, you must make your request in writing to the Privacy Officer (address below). In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosures to your spouse. We are not required to agree to any restriction you request, with a limited exception for requests to restrict disclosures to your health plan related to services you have paid in full out of pocket. If we do agree to adhere to your restriction, we will comply with your request unless the information is needed to provide you emergency treatment or until you let us know that you do not want us to continue to comply with your previous request.

The Right to Inspect and Obtain a Copy
You have the right to inspect and obtain a copy of your medical information, with the exception of psychotherapy notes. To inspect and copy medical information, you must submit your request in writing to the Privacy Officer (address below). If you request a copy of the information, you may request paper or electronic copies and we may charge a fee for the costs of copying, mailing or other supplies associated with your request. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed in some instances. Another licensed health care professional chosen by us will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.

The Right to Request an Amendment
You have the right to request an amendment (correction) to your health record if you feel that the information we have about you is incorrect or incomplete. You have the right to request an amendment for as long as we keep the information. To request an amendment, your request must be made in writing and submitted to the Privacy Officer (address below). In addition, you must provide a reason that supports your request.

Although you are permitted to request that we amend your medical information, we may deny your request if it is not in writing or does not include a reason to support your request. In addition, we may deny your request if you ask us to amend information that:
— Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
— Is not part of the medical information we keep;
— Is not part of the information which you would be permitted to inspect and copy; or
— Is accurate and complete

The Right to an Accounting of Disclosures You have the right to receive a list of the disclosures of your medical information that we have made, with some exceptions. To request this list, you must submit your request in writing to the Privacy Officer (address below). Your request must state a time period which may not be longer than six years and may not include dates before April 14, 2003. The first list you request within a twelve month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

The Right to Request Confidential Communications
You have the right to request that you receive confidential communications regarding your medical information in a certain form or at a certain location. For example, you may request a private conference area or ask that we only contact you at work or by mail. To request confidential communications, you must submit your request in writing to the Privacy Officer (address below). In addition, your request must specify how or where you want to be contacted. We will not ask you the reason for your request. We will use our best efforts to accommodate all reasonable requests.

The Right to a Paper Copy of This Notice
You have a right to receive a paper copy of this Notice at any time, even if you have agreed to receive this Notice electronically. You may obtain a paper copy of our current Notice by (1) asking for a copy of the Notice to take home with you the next time you visit or receive health care services at St. Anthony’s Medical Center or one of its affiliates, or (2) submitting your request in writing to the Privacy Officer (address below).

Complaints

If you believe your privacy rights have been violated, you may file a written complaint with us or with the Secretary of the U.S. Department of Health and Human Services. You may file a written complaint with us by mailing it to the Privacy Officer (address below).

Any complaint should be in writing, stating the nature of your complaint, and how to contact you. You will not be retaliated against for filing a complaint, and your complaint will not affect any treatment that we provide to you.